Germany's BFSG: Which websites have needed to be accessible since June 2025?

Germany's Accessibility Strengthening Act, known as the Barrierefreiheitsstärkungsgesetz or BFSG, has applied since 28 June 2025. It requires certain businesses to make their products and services accessible. Online shops and digital services for consumers are among the activities that can be covered. However, not every business website automatically falls within the Act. This article explains which offerings are covered, what exemptions exist and what website operators should check.

What is the BFSG?

The BFSG implements EU Directive 2019/882 in Germany. The Directive is also known as the European Accessibility Act.

Its aim is to make certain products and services usable by people with disabilities as independently as possible.

This includes people with visual or hearing impairments, motor impairments or difficulties processing complex information.

In this context, accessibility means designing digital offerings so that they are perceivable, operable, understandable and technically accessible.

The BFSG has generally applied since 28 June 2025. The accompanying German regulation, the BFSGV, sets out more detailed accessibility requirements.

Which websites are covered by the BFSG?

A common misconception is that every website in Germany has had to be accessible since June 2025.

That is not the case.

The BFSG covers specific products and services defined by law. For website operators, e-commerce services are particularly relevant.

These are digital services provided at a consumer's individual request with a view to concluding a consumer contract.

Typical examples include:

• Online shops where consumers can order products.
• Websites through which paid services can be booked directly.
• Certain digital booking and contract processes.
• Online banking and other services expressly covered by the Act.
• Certain ticket-booking services and electronic ticket services.

Associated mobile applications may also be covered.

The decisive question is not simply whether a website is operated commercially, but which functions and services it provides.

For a covered online shop, it is important to look beyond the final checkout step. Germany's Federal Accessibility Agency takes the view that the requirements generally extend to the entire associated website or app. Specific statutory exclusions for certain content must be assessed separately.

Do purely informational business websites have to be accessible?

A website that merely presents a company's services does not automatically fall within the BFSG.

This can include a conventional information website without an online shop or a corresponding digital process aimed at concluding a consumer contract.

A contact form or newsletter signup does not settle the question by itself. What matters is its specific function and connection to a consumer contract. A form is neither a blanket trigger nor an automatic exemption.

The situation may differ where a website enables consumers to initiate concrete contract negotiations or conclude contracts directly.

The actual business model therefore needs to be considered. Services aimed exclusively at businesses must also be distinguished from offerings directed at consumers.

What exemptions apply to very small businesses?

The BFSG contains an important exemption for microenterprises.

Businesses providing services are generally exempt if they:

• employ fewer than ten people, and
• have either annual turnover of no more than EUR 2 million or an annual balance-sheet total of no more than EUR 2 million.

The employee threshold and at least one of the two financial thresholds must both be met.

Important: This exemption concerns the provision of services. Microenterprises manufacturing or placing products covered by the BFSG on the market are not exempt merely because of their size.

The exemption also does not mean that accessible websites are unimportant for small businesses.

A more accessible website often improves usability for a wider audience.

What requirements must covered websites meet?

The BFSGV sets out more detailed accessibility requirements.

Four basic principles are especially important for websites and online applications.

1. Perceivability

Content needs to be presented in ways that different people can perceive.

Examples include:

• sufficient colour contrast,
• descriptive alternative text for meaningful images,
• readable text sizes,
• captions for relevant video content,
• clear labels for form fields.

Important information should not be conveyed through colour alone.

2. Operability

A website should be usable without a mouse.

Keyboard navigation is particularly important.

Menus, buttons and forms need to be reachable, and users should be able to see clearly which element has focus.

Distracting animations or content that changes automatically can also make a website harder to operate.

3. Understandability

Navigation and interactions should be easy to follow.

Forms need clear labels and useful error messages.

During checkout, users should understand which information is required and how to correct mistakes.

4. Robustness

Websites need a technical structure that works with different devices and assistive technologies.

These include screen readers, which present website content through speech or other output.

Clear HTML structure and correctly marked-up controls are particularly important.

What role do WCAG and technical standards play?

The Web Content Accessibility Guidelines (WCAG) play an important role in the technical implementation of accessible websites.

They provide internationally recognised guidance on digital accessibility.

In the European context, EN 301 549 is particularly relevant as a technical reference. It describes accessibility requirements for information and communication technology and refers to WCAG criteria.

WCAG conformance level AA is therefore an important practical reference point.

However, meeting individual WCAG criteria does not automatically demonstrate compliance with every BFSG requirement. The applicable version of a standard and any legally relevant publication or reference also need to be checked.

Information obligations and any service-specific requirements must be considered as well.

Do covered websites need accessibility information?

Yes. Businesses providing services within the BFSG's scope have additional information obligations.

Under section 14 BFSG and Annex 3, they must explain accessibly how their service meets the applicable accessibility requirements.

This includes a description of the service, information needed to understand how it works and details of the responsible market-surveillance authority.

The information must be publicly available and itself accessible.

A clearly visible link labelled “Accessibility” in the footer can provide an appropriate route to it.

This information is not automatically the same as the accessibility statement required for certain public-sector bodies under separate legislation.

What can happen if a business breaches the BFSG?

The responsible market-surveillance authorities monitor compliance with the Act.

If they identify a breach, a business may initially be asked to remedy the problems.

Depending on the circumstances, further administrative measures and fines are possible.

It is therefore sensible to review accessibility before complaints arise.

For larger online shops in particular, fixing complex checkout processes at a later stage can involve considerable work.

What should website operators check now?

A basic accessibility review is worthwhile even if a website does not directly fall within the BFSG.

The following areas are especially important:

1. Navigation: Can all essential functions be used with a keyboard?
2. Images: Do informative images have suitable alternative text?
3. Contrast: Are text and controls readable in different lighting conditions?
4. Forms: Are fields clearly labelled and error messages understandable?
5. Mobile devices: Does the website work with enlarged text and on small screens?
6. Structure: Are headings used logically and is content organised clearly?
7. Checkout: Can users complete every step without unnecessary barriers?

Automated tools such as Lighthouse or axe can help identify technical problems.

They do not replace a complete accessibility assessment. Keyboard and screen-reader use should also be tested in practice.

Is accessibility useful for SEO too?

Accessibility and search engine optimisation have different aims, but some of their practical measures overlap.

A clear heading structure, meaningful link text and descriptive image alternatives help people and search engines understand content.

Straightforward navigation and readable information can also improve usability.

However, accessibility is not a blanket ranking bonus in Google Search.

A website does not automatically rank better simply because it is accessible.

Nevertheless, accessibility work can improve the overall quality and usefulness of a website.

Conclusion: Not every website is covered, but accessibility is worthwhile

Since 28 June 2025, Germany's BFSG has applied to certain products and services offered to consumers.

It is especially relevant to online shops and other digital offerings aimed at concluding consumer contracts.

Purely informational websites do not automatically fall within the Act. There are also important exemptions for microenterprises providing services.

Regardless of the legal obligation, it is worth checking a website for barriers.

Clear information, a logical structure and straightforward interactions benefit visitors more broadly.

Note: This article provides general editorial information about German legislation, not individual legal advice. Whether a particular website falls within the BFSG depends on its offering and circumstances. The BFSG is Germany's implementation of an EU directive. Do not assume that the same rules, exemptions or enforcement arrangements apply in Austria, Switzerland, elsewhere in the EU or internationally. Businesses serving consumers in Germany should assess whether German requirements apply to their own activities.